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Compliance Programs and Ethics Issues

Diego Venegas, Mining Agreements: Contracting for Goods and Services

• What's wrong with Bribery?
• Comparative between UK, US and Canadian laws around foreign corruption of public officials
• Facilitation payments
• Books and Records
• Elements of a good compliance program
• Practical implementation recommendations related to mining


What's wrong with Bribery?

“Corruption is a considerable obstacle to economic and social development around the world. It has negative impacts on sustainable development and particularly affects poor communities.

For companies, corruption impedes business growth, escalates costs and poses serious legal and reputational risks. It also raises transaction costs, undermines fair competition, impedes long-term foreign and domestic investment, and distorts development priorities. Investors too understand that corruption can negatively impact value and pose financial, operational and reputational risks to their investments”1


• Illegal in virtually every country in the world
• Perpetuates poverty - inequitable distribution of wealth
• Creates further demand for bribes (sets a precedent with no escape)